Pia

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]

Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.
Privacy Threshold Analysis – IC/Form

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:
Form Title:
Component:

FEMA Form 086-0-31 (Previously FEMA Form 81-112)
Statement of Voluntary Participation for Acquisition of Property
for Purpose of Open Space
Federal Emergency
Office:
Federal Insurance and
Management Agency
Mitigation
(FEMA)
Administration (FIMA)
Hazard Mitigation
Assistance (HMA) Grants
Policy

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Property Acquisition and Relocation for Open Space
January 31, 2018
OMB Control
1660-0103
OMB Expiration
Number:
Date:
Collection status:
Revision
Date of last PTA (if
N/A
applicable):
Name:
Office:

Phone:

PROJECT OR PROGRAM MANAGER
Jennie Orenstein
HMA Policy, Tools, and
Title:
Branch Chief
Training
202-212-4071
Email:
[email protected].
gov

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Name:
Office:

Phone:

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Roselyn Brown-Frei
HMA Policy, Tools, and
Title:
Supervisory Program
Training
Analyst
202-549-1849
Email:
[email protected]
SPECIFIC IC/Forms PTA QUESTIONS

1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
FEMA’s FIMA submits this new PTA for FEMA Form 086-0-31 (previously FEMA Form
81-112) Statement of Voluntary Participation for Acquisition of Property for Purpose
of Open Space which is part of the Office of Management and Budgets (OMB)
Information Collection Request (ICR) Control No. 1660-0103.

Form 086-0-31, as part of ICR 1660-0103, supports the implementation of 44 CFR Part
80 and related property acquisitions by requiring the collection of information from
grant applicants (States, the District of Columbia, U. S. Territories and Federallyrecognized tribes applying as applicants) and sub-applicants (local governments, state
agencies, state-recognized tribes and Alaskan villages applying as sub-applicants) to
ensure that property acquisitions are voluntary, and that the acquired property remains
open space in perpetuity. FEMA collects copies of the deed restriction language from
Applicants as a pre-award requirement for mitigation grants to ensure that the deed to
be recorded meets the minimum legal and program requirements.

FEMA Form (FF) 086-0-31, Statement of Voluntary Participation for Acquisition of
Property For Purpose of Open Space is signed by both property owners and local
community officials to enforce the requirement that all acquisitions using FEMA
mitigation grants are voluntary, and that no property is acquired using State, Territorial,
local, or Tribal eminent domain authorities or other forcible acquisition procedures per
44 CFR 80.11.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

b. List the DHS (or component) authorities to collect, store, and use this information.
If this information will be stored and used by a specific DHS component, list the
component-specific authorities.
FEMA published a Final Rule on Property Acquisition and Relocation for Open Space (44
CFR Part 80), governing property acquisitions under FEMA’s three Hazard Mitigation
Assistance (HMA) grant programs, on September 16, 2009. Of the three HMA programs,
Pre-Disaster Mitigation (PDM) and the Hazard Mitigation Grant Program (HMGP), are
authorized under Sections 203 and 404 of Robert T. Stafford Disaster Relief and
Emergency Assistance Act of 1988, P.L. 93-288 (42 U.S.C. § § 5133 and 5170c), as
amended. The Flood Mitigation Assistance (FMA) program is authorized under Section
1366 of the National Flood Insurance Act (NFIA) of 1968 (42 U.S.C. 4104c), as amended.
2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

c. Who will complete and
submit this form? (Check
all that apply.)

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☐ Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.

☒ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney,
etc.).
☒ Business entity.

1
Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

d. How do individuals
complete the form? Check
all that apply.

If a business entity, is the only
information collected business contact
information?
☒ Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
Click here to enter text.

☒ Paper.
☒ Electronic. (ex: fillable PDF)
☐ Online web form. (available and submitted via
the internet)
Provide link:

e. What information will DHS collect on the form? List all PII data elements on the
form. If the form will collect information from more than one type of individual,
please break down list of data elements collected by type of individual.
FF 086-0-31: FEMA collects some or all of the following information from HMA Grant
Program Property Owners: Name, title, property address, or signature. From HMA Grant
Program Subgrantee’s POC: Name, signature
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? No
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

g. List the specific authority to collect SSN or these other SPII elements.
N/A
h. How will this information be used? What is the purpose of the collection?
Describe why this collection of SPII is the minimum amount of information
necessary to accomplish the purpose of the program.
N/A
i.

Are individuals
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

☒ Yes. Please describe how notice is provided.
Participating property owners have notice of
the collection upon voluntarily entering into
the grant agreement for acquisition and
demolition or relocation activities.
☐ No.

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
FEMA Regional Offices collect and store paper
completed IC/forms?
applications
☒ Electronic. Please describe the IT system that will
store the data from the form.
Data collected by this form for grants awarded
under Hazard Mitigation Grant Program
(HMGP) is stored in the HMGP System, a webbased data management system for collection,
processing and storage of data and
information that is used by grant Subapplicants or by Applicants to administer
program information and grant applications
under HMGP. Paper forms requiring the
signature of participating property owners,
are scanned and electronically filed by FEMA.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Data for grants awarded under PDM or FMA is
processed and stored in Mitigation (MT)
eGrants, a two-part (External and Internal)
online grant management system. The
External MT eGrants system is used by
Applicants and Sub-applicants to prepare and
submit PDM or FMA applications for mitigation
activities to FEMA. Signed paper forms are
scanned and uploaded to MT eGrants.
FEMA uses the Internal Mitigation eGrants
system to review, select, award and store
applications for mitigation assistance, and
monitor grant performance.
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
FEMA stores original scanned paper forms for
HMGP applications into a secure Local Area
Network (LAN) repository; original scanned paper
forms for PDM and FMA applications are stored in
MT eGrants.
b. If electronic, how
does DHS input the
responses into the IT
system?

Privacy Threshold Analysis – IC/Form

☒ Manually (data elements manually entered). Please
describe.
Mitigation eGrants is a FEMA system that is
fully accessible by FEMA. Applicants and Subapplicants manually input responses into
Mitigation eGrants for PDM or FMA
applications.
HMGP application responses are manually
input into the HMGP System by grant Subapplicants. Applicants use the HMGP System to
administer program information and grant
applications under HMGP. FEMA does not
input responses into either system.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

2

☐ Automatically. Please describe.
Click here to enter text.

☐ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Click here to enter text.
☒ By a non-personal identifier. Please describe.
The identifier (sub-application title) used by
FEMA for HMA grants under HMGP consists of
the disaster number, affected State or
Territory abbreviation, project number and
State name.
The sub-application title used for PDM and
FMA grants consists of the HMA program
acronym, abbreviation for project or plan,
FEMA Region number, state or territory
abbreviation, and sub-application year.
TEMPORARY. Delete file 6 years and 3
months after grant is closed, and final audit
and any appeals are resolved and completed;
Records Schedule Number: MIT-1-3.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
Each FEMA Regional Office has a Records
that records are
Management Specialist who prepares and updates
disposed of or deleted
a Mitigation File Plan and Retention Schedule.
in accordance with
Proper retention and disposal per the retention
the retention
schedule is systematically ensured by the Records
schedule?
Management Specialist and respective HMA Office.
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Click here to enter text.
☒ No. Information on this form is not shared outside of the collecting office.

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:
Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

JoAnna Gorsage
February 11, 2021
February 18, 2021

☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
While information is not stored and
retrieved using an individual’s name or
other unique identifier for this
collection, A Privacy Act Statement is
provided on form 086-0-031. The form
is attached for review.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
FEMA Privacy recommends that FEMA Form 086-0-31 is categorized as Privacy
Sensitive. This form collects Name, title, property address, and signature from the
HMA Grant Program Subgrantee’s Property Owners and the name and signature
from the HMA Grant Program Subgrantee’s POC.
Since these forms relate to HMA Grants awarded to States and Territories, FEMA
retrieves files/records by the State or Territory name, FEMA Disaster Number, or
Grant project number/information and not by any unique identifier.
The FEMA Privacy Branch provides the following recommendation for compliance
coverage:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PIA(s): DHS/FEMA/PIA-006 FEMA National Emergency Management Information
System Mitigation Electronic Grants Management System and DHS/FEMA/PIA-025
Hazard Mitigation Grant Program (HMGP) System.
While SORN coverage is not required for this form, FEMA Privacy believes
DHS/FEMA-009 Hazard Mitigation Disaster Public Assistance and Disaster Loan
Programs provides additional coverage.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Joseph Thomas

PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

Click here to enter text.
April 27, 2021
April 27, 2024

DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

DHS IC/Forms Review:

Choose an item.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☒ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☐ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Choose an item.
Statement:
Click here to enter text.
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

If covered by existing PIA, please list: DHS/FEMA/PIA-006 FEMA
National Emergency Management Information System Mitigation
Electronic Grants Management System; DHS/FEMA/PIA-025 Hazard
Mitigation Grant Program (HMGP) System
If a PIA update is required, please list: Click here to enter text.
SORN:
Choose an item.
If covered by existing SORN, please list: Click here to enter text.
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.

FEMA has submitted this new PTA for FEMA Form 086-0-31 (previously FEMA Form
81-112) Statement of Voluntary Participation for Acquisition of Property for
Purpose of Open Space, which is part of the Office of Management and Budgets
(OMB) Information Collection Request (ICR) Control No. 1660-0103.
These forms support acquisitions by requiring the collection of information from
grant applicants to ensure that property acquisitions are voluntary, and that the
acquired property remains open space in perpetuity. FEMA collects copies of the
deed restriction language from applicants as a pre-award requirement for
mitigation grants to ensure that the deed to be recorded meets the minimum legal
and program requirements.
This form is signed by both property owners and local community officials to enforce
the requirement that all acquisitions using FEMA mitigation grants are voluntary,
and that no property is acquired using eminent domain authorities or other forcible
acquisition procedures.
DHS PRIV concurs that this constitutes a privacy-sensitive system, and requires PIA
coverage. Coverage is provided by DHS/FEMA/PIA-006 FEMA National Emergency
Management Information System Mitigation Electronic Grants Management System
and DHS/FEMA/PIA-025 Hazard Mitigation Grant Program (HMGP) System.
SORN coverage is not required, as PII is not retrieved by unique identifier.
DHS PRIV has reviewed the associated Privacy Act Statement and finds that it is
compliant.

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